Comment Analysis · Docket FS-2025-0001

FS-2025-0001-602437

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment establishes that the agency's DEIS contains internal contradictions regarding wildfire ignition rates on roaded lands, bird abundance impacts from road noise, and economic net benefits, and documents specific geographic locations (Santa Rita, Sierra Nevada, Siskiyou, White Mountain) where these deficiencies directly impact wildlife corridors and water headwaters.

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
EA analysisEngages the agency's environmental analysis directly.
Analytical gapIdentifies something the analysis fails to address.
EvidenceBacks claims with specific facts, data, or research.
RequestMakes a specific, actionable request of the agency.
AlternativeProposes a different course of action.
LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Still open to the agency

Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.

Topics

Wildlife Habitat
- “bird and plant species that depend on undisturbed ecosystems”
- “habitat that disappears the moment a road goes in”
- “bird richness declines with road presence”
- “jaguars have been documented crossing from Mexico through the Santa Ritas”
Forest Management Wildfire
- “Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires”
- “human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands”
- “far higher fire density on roaded land than inside the affected roadless areas”
Economic Impact Fiscal
- “total timber volume affected by this rule is less than 0.5 percent of total United States production”
- “recreation losses of at least $6.1 million a year”
- “net present value spanning -$92 million to +$199 million”
- “road system already carrying a $6.9 billion maintenance backlog”
Water Quality Quantity
- “headwaters for rivers supplying drinking water to communities”
- “across New Hampshire, Vermont, and Massachusetts”

What it names

National Forests: White Mountain National Forest
Roadless areas: Santa RitaWhite Mountain
Law cited: 36 C.F.R. Section 294.12

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeLocal knowledgeEA analysisAnalytical gapEvidenceRequest

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Much of my free time goes to exploring wilderness, and a great deal of it falls inside roadless rule areas: the Santa Rita Mountains in Arizona, the Sierra Nevada, across the Siskiyou, and in the east, White Mountain National Forest. I go looking specifically for the bird and plant species that depend on undisturbed ecosystems, the kind of habitat that disappears the moment a road goes in. This proposal would rescind the protections that make those places worth the trip, and I oppose it. The agency's own evidence on wildfire undercuts the rationale for rescission. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency is justifying this rescission partly on fuels management grounds, it needs to explain why it is departing from that finding. I ask that it reconcile this proposal with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain what in the current record overrides what the agency itself documented. The birds I look for across the Siskiyou, the Sierra, the Santa Ritas, and the White Mountains are not incidental to the roadless rule. They are a direct product of it. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The Coronado's verified species list includes the elegant trogon and the Mexican spotted owl, and the White Mountain's includes Bicknell's thrush, each tied to the undisturbed conditions the rule protects. The 23 inventoried roadless areas of the Coronado total 482,687 acres, the Santa Ritas among them, and jaguars have been documented crossing from Mexico through the Santa Ritas into the Rincon Mountains, making those corridors the northernmost viable jaguar range on the continent. Opening any of it to road-building does not merely disturb habitat at the road's edge. It degrades the surrounding area through noise and fragmentation. The agency must address in the record how rescission squares with its own documented findings on road noise and bird abundance, and what specifically it expects to happen to species dependent on those corridors once the rule is gone. The economics do not hold up either. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. A cost-benefit analysis that cannot establish a net benefit is a thin foundation for expanding a road system already carrying a $6.9 billion maintenance backlog. The agency should reconcile the proposal with those numbers. The state-by-state approach this proposal gestures toward has already been tried and overturned. The record itself acknowledges: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified when the national rule was last replaced with a state-by-state framework. Finally, the rule the agency proposes to rescind already contains the flexibility it claims to need. The DEIS acknowledges: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. If the agency's concern is genuine administrative burden, it should identify which specific situations are not already addressed by the existing exceptions for health, safety, and existing mineral rights, and it should quantify those burdens with actual data rather than assertion. Sincerely, Timothy Forker Brooklyn, NY